Dallas AIChE Meeting April 24, 2012

Don Abrahamson

Process Safety Consultant

Abrahamson Consulting LLC

Phone: 972-514-9718

eMail: don@globalprocesssafety.com

CCPS – Center for Chemical Process Safety

MOC – Management of Change

eMOC – Electronic Management of Change

PSSR – Pre-startup Safety Review

SIS – Safety Instrumented System

NEP – National Emphasis Program

RFC – Request for Change

KMS – Knowledge Management System

SOP – Standard Operation Procedures

PSI – Process Safety Information

RAGAGEP – Recognized and General Accepted Good Engineering Practice

PHA – Process Hazard Analysis

HAZOP – Hazard and Operability Study (aka PHA)

RIK – Replacement in Kind

RCA – Root Cause Analysis

CPI – Chemical Process Indusgtry

Worked in the CPI for 45 years

Retired from Occidental Chemical in 2006 as the Director of Risk Engineering and Process Safety to join Celanese

Retired from Celanese in 2010 as the Global Process Safety Manager

Formed Abrahamson Consulting LLC in 2010 • AIChE - Center for Chemical Process Safety (CCPS) Staff

Consultant

• Clients include: BP; Occidental Oil and Gas; Olin; Invista; PAS; Enerkem; Cabot; Celanese; ABB; E.Vironment and API

Sustainable Process Safety Management Systems

CCPS Risk Based Process Safety

Management of Change MOC

• Why manage change

• MOC Overview

• MOC Systems - MOC Procedures

• Sources of change

• MOC Challenges and potential solutions

• Thoughts on MOC Metrics

Tribal Sustainable (Operational Excellence)

Failures Bureaucracy

Weak Documented Management Systems

Skilled /

Trained

Peo

ple

Document & Standardize Knowledge

Tra

in a

nd

/or S

imp

lify

MOC

Bellows failed after 3 months of service from torsional stresses

30 tons of cyclohexane released

Ignition and vapor cloud explosion

28 fatalities and 87 injuries, some injuries off site

Occurred on Saturday when only operating staff present

Recognize that there is a change

Include the right multidisciplinary expertise

Use the right hazard analysis technique

Authorize the changes at the level appropriate considering the hazards and risks

Communicate the new operating procedures in writing including the hazards and safe operating limits

Provide appropriate training

13

Change — any change (modification) to process chemicals, technology, equipment, or procedures and changes to facilities that affect a covered process except

• Replacement in kind (A replacement which satisfies the design specification)

• Those that satisfy the design specifications

Many companies apply their MOC system to all process and not just covered process

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Helps to ensure that changes to a process do not inadvertently introduce new hazards or unknowingly increase the risk of existing hazards

Includes a review and authorization process for evaluating proposed adjustments to facility design, operations, organizations

System to ensure that introduced changes are thoroughly scrutinized prior to implementation • More than 80% of large losses are related to change

• 9% of OSHA Refinery NEP citations were for MOC

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All changes must be evaluated, communicated and coordinated prior to execution

Rational basis required to initiate the process.

Applies to physical equipment, products, operating conditions, staffing, (Plus?)

Includes organizational changes

Includes these types • Permanent changes • Temporary changes • Emergency changes including bypassing of safety critical

equipment • Personnel changes

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Classic MOC Flowchart Example

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Proceed outside of MOC system

Complete RFC and file to allow auditing

Conduct review by an individual to identify potential hazards and associated tasks. Document controls required for implementation.

Source: CCPS book on Management of Change

Identify need for change

Prepare request-for-change form (RFC)

Is proposed change to be pursued?

Is change per MOC definition?

Is multi-disciplinary review required?

Conduct multi-disciplinary review to identify potential hazards and associated tasks. Document controls required for implementation.

A

Initial

Review

Classification

Review

Hazard

Review

Who can initiate

change? Can anyone in

the facility

Could be performed by

the originator or one

designated person

YES

YES

YES

NO Complete RFC and return to originator

NO, RIK

A

MOC Flowchart Continued

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A

Source: CCPS book on Management of Change

Complete tasks identified as required before implementation

Have all pre-implementation tasks been completed?

Authorization

Review

Close-out

Review

Implement change using controls specified by site procedures and MOC

review

Have all post-implementation tasks been completed?

Complete MOC documentation and file

YES

YES

NO

Complete post-implementation tasks

NO

Common to see multiple MOC procedures (PSI, Procedure

“SOPs”, Pipe Clamps, Facility, Personnel, Temporary

Trailers, Temporary By-passes…)

eMOC (Stature, KMS, Home Grown) • KMS is the eMOC system that I have seen the most (OXY, BP…)

• Home grown systems (Celanese, Albermarle, Olin, BP)

Hybrid systems • eMOC – PSM regulatory higher risk changes to PSI

• Paper MOC – Non-PSI, non-PSM, lower risk…

Chemical industry more risk driven

Refining / Oil and Gas industry more regulatory driven

Classic PSM - changes to PSI (permanent, temporary and emergency)

Procedure

Interlock by-pass

Leak repair

Facility – Siting and temporary buildings

Personnel

Quality

Non-PSM

Rarely do sites capture all MOCs in one MOC system

Engineering studies (trouble shooting, capacity

increase, new products, process improvements)

Obsolete equipment replacement

Failed equipment

SIS By-pass

Corrective actions from incident investigations (RCA)

Corrective actions from audits

Recommendations from Process Hazard Analysis

(PHA)

Other?

Technical Basis often not under stood

• Often people restate the purpose of the change

• Engineering design basis

• Company engineering standard

• Recognized and Generally Accepted Good Engineering

Practice (RAGAGEP)

Determining the appropriate level of Hazard Review

• Example tool – Simple 2 X 2 “Risk Matrix”

• Training of affected employees

Example MOC Metrics

Level of hazard review not always appropriate

Review level should be commensurate with risk

Level I – Completed for all MOCs (Basic check list to

identify hazards)

Level II (Expanded check list with “What If” brainstorming)

Level III (HAZOP or equivalent)

Significance of Change

Low High

Degree

of

Hazard

Low Level 1 Level 2

High Level 2 Level 3

Four suggested types:

Training – Class room with testing (~1%) • MOC Trainer prepares training material

• Training materials presented

• Employees are tested – test records are evidence of training

Training / Notification – Presentation with no testing (~10%)

• MOC Trainer prepares presentation

• Presents material to employees

• Employees sign attendance sheet, which is evidence of training

Notification – Email with no testing (~80%)

• MOC Trainer prepares and sends email with read receipt requested

• Email read receipt is evidence of training

Awareness – Email with no read receipt (~9%)

• MOC Training prepares and sends email

• Email is saved as evidence of training

Number of RIKs

Number requests not initiated

Number of MOCs initiated by type

Number of MOCs by risk classification (Level I, Level II

and Level III)

Number of MOCs completed incorrectly

Number of qualified Level III reviewers

Number of Temporary MOCs

Number of Emergency MOCs

Number of PSSR completed incorrectly

Number of MOC implemented prior to completion of the

PSSR

Number of open MOCs

Average length of time MOCs are open

Number of MOCs in approval / review process

Average time (days) to approve MOCs

Average time (days) to close MOC after start-up

Oldest MOC

Number of times MOC are “touched” (opened, updated,

reviewed, approved…)

Don Abrahamson

Process Safety Consultant

Abrahamson Consulting LLC

4013 Eastleigh Dr.

Plano, TX 75024

Work: 972-294-5711

Mobile: 972-514-9718